2000 Ruling 2000-0015753 - Article 13 - Canada-Netherlands Treaty -- summary under Article 13

A disposition by a Netherlands resident of shares of a Canadian corporation (perhaps a Canadian holding company holding a Canadian oil and gas operating subsidiary) qualified for exemption under the Netherlands Treaty having regard to the exclusion from immovable property for property (other than rental property) in which the business of the company was carried on given that the operating company was using its oil and gas properties in its Canadian business. The CRA summary states that this "exception applies on a look-through basis."